• The mining company cannot be considered to have achieved a social license to operate until the information gaps on environmental and socio-economic impacts are filled and independently endorsed mitigation strategies are developed. In addition, due to the lack of good governance and accountability demonstrated to date, independent monitoring by a team of experts and civil society representatives should continue throughout the life of the project and any subsequent projects.

• Due to the high level of uncertainty associated with deep sea mining (DSM), it is not possible to predict the impacts of any individual DSM project, let alone the cumulative impacts of the many potential DSM projects.

• It is particularly of concern in national waters where governments do not have environmental regulatory systems specific to DSM, or the capacity to enforce regulations and conduct independent monitoring. In international waters, no authority is empowered to ensure the protection and conservation of the biological resources of the seabed.

Another significant report related to DSM in Papua New Guinea was released in November 2012, entitled “Physical Oceanographic Assessment of the Nautilus EIS for the Solwara 1 Project”.

It is authored by an oceanographic expert, Dr. John Luick who has over twenty years of experience in projects related to ocean monitoring, tidal analysis, and hydrodynamic modelling. He has numerous publications and technical reports as well as a wide experience in teaching, consulting, and shipboard observations. Most of his work has been in “marginal seas” similar to the Bismarck Sea, as well as in the deep Pacific Ocean and on the shallower waters of the continental shelf.

The report draws the attention because of the issued fact that “… much of the Environmental Impact Statement (EIS) is simply too general in nature to determine impacts, and many of the mitigations proposed rely upon Environmental Management Plans and procedures that have yet to be developed by Nautilus, and thus the effectiveness of these cannot be judged at present. It is likely that the project would result in severe, prolonged, and perhaps region-wide impacts to a globally rare and poorly understood biological community, and it is clear that the EIS does not adequately assess many of these impacts. Further, the benefits to local people or the economy of PNG seem disproportionately low compared to the scale and risk of the project”.

It added this significant declaration about the Report’s conclusions about the EIS:

“It seriously downplays the risks facing local communities and the marine environment. … The oceanographic aspects of the EIS suffer from a lack of ragout. There are many errors and omissions in the modeling, presentation and analysis of data”.

The Report reviews the oceanographic elements of the EIS for the project in PNG. Its focus is on currents and upwelling that may bring pollutants into contact with local populations and marine species. The risk is with the possibility of upwelling and currents carrying mine-derived metals towards the coastline.

The author of the report Dr. Luick said:

“The physical oceanography and hydrodynamic components of the EIS are second-rate. The shortcomings in these elements of the Solwara 1 EIS are so basic that I could have written the same review 27 years ago while still a student. The modeling is completely unacceptable by scientific standards. The People of PNG deserve better. They should be able to feel confident that the approvals process is open and based on the best available science.”

Dr. Helen Rosenbaum voiced this opinion:

“As such it demands extremely careful attention to scientific detail and transparency in decision making. This new report indicates that both of these elements have been lacking. Important next steps are to make available the full data set behind the EIS”.

In the Foreword to the report it is observed that

“The EIS should provide a clear and rigorous assessment of potential hazards and impacts. It should provide the groundwork for comprehensive risk analysis and the development of mitigation strategies. Most importantly the EIS should have provided a solid basis for the Government of PNG to decide whether to approve this project and if so, under what conditions. Tis review demonstrates that the EIS fails to provide solid ground for informed decision-making”.

In the Overview section of the Report it is stated:

“In summary, there are serious omissions and flaws in information presented in the EIS about surface currents, the speed and direction of currents at different depths, and about tides. These deficiencies mean that several important risks to the marine environment and to local communities cannot be determined. These include the risks of pollution from spills from vessels at the surface, leakage from the riser or discharge pipes, and of upwelling dispersing metals from the mining activity or from the discharge water. The implications of these risks – especially for the people of New Ireland and possibly also East New Britain Province – demands that a thorough and independently verified analysis of currents be conducted as a basis for a comprehensive risk assessment”.

Dr. Luick at the end of the Report concluded:

“The authors of the EIS had access to excellent physical oceanographic data sets and modeling capacity. The EIS should have presented a clear and comprehensive picture of the physical ocean environment as a basis for environmental risk assessment and management. It has failed to do so”.